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 Below you will find one of the two complaints that led to the Indiana GOP reprimanding St. Joseph County Chairwoman Jackie Horvath. This complaint is from Joe Layne, former SJC vice chair.  

Executive Summary

I respectfully request direct consideration of this complaint by the Indiana Republican State Committee due to the serious nature of the following violations. I am requesting the removal of the St. Joseph County GOP Chair Jackie Horvath and/or the classification of her as a Republican not in good standing.

While this is an unprecedented situation, I firmly believe that Chairwoman Horvath’s repeated attempts to damage the party’s reputation by her failure to adhere to state party rules is leaving the party with no other choice. Chairwoman Horvath must remove her from her post so that we can rebuild and unify the party. It is important to note that every option to reconcile has been made by long-standing party donors, elected federal, state, county officials, devoted party volunteers, and countless former precinct committeeman.

Chairwoman Horvath came into office promising to fix a party left in shambles by disgraced former chairman Tyler Gillean and pledged transparency and accountability. To date, no effective actions have been taken to unify the party, provide transparent financial reports to all dues paying members, and to hold Republican not in good standing County Councilman Dan Schaetzle accountable for his behavior. Chairwoman Horvath continues to double down on withholding basic support to incumbents in good standing who did not support her in the reorganization vote, while providing funding, the use of an email distribution list reaching thousands, and speaking opportunities to those who endorsed her in the caucus.

Chairwoman Horvath has completely reshaped her precinct list to exclude those who are not in full alignment with her. The Republican Party was founded on uniformity of principles, not uniformity of thought, and Chairwoman Horvath has abandoned that. Since the March 1 caucus, Chairwoman Horvath has made approximately 150 changes to the list. She has used the list to punish even elected officials by removing them as precinct chairs or demoting them to vice chairs. Her additions include innumerable names that cannot be identified as valid Republicans or dues-paying/participating members.

Furthermore, Chairwoman Horvath almost exclusively uses consultant Sam Barke -- a pattern that was established under disgraced chairman Tyler Gillean – despite the appearance of several conflicts of interest.

For the good of the party, this behavior cannot be allowed to continue, as it damages the reputation of the SJCGOP, the Indiana state GOP, and the entire Republican brand.

Rules Violations by Chairwoman Horvath

Rule 1-30 states that complaints include a variety of items. It is my position that this complaint shows that Rule 1-30(3) supports the removal of a member of the county committee – specifically the St. Joseph County Party Chair. Rule 1-30 does not limit complaints, so this complaint also seeks the classification of the St. Joseph County Party Chair as a Republican not in Good Standing for two years.

Rule 1-13 defines “Cause” to include willful violation of the State Committee Rules as well as willful violation of a resolution of the State Committee. It also includes gross misconduct affecting the party organization.

The Chair’s actions repeatedly violate this Rule (1-13). 

For instance – 

WILLFUL VIOLATION OF A RESOLUTION OF THE STATE COMMITTEE

 - the chair has violated the State Committee’s determination that Schaetzle is a Republican not in good standing by the following actions or inactions:

   • Absolutely no SJCGOP party notification whatsoever that County Councilman Dan Schaetzle was declared by the state as a Republican Not in Good Standing and the ramifications of that. This means that Chairwoman Horvath did not communicate with members about this major development in any way, including in written or verbal form.

   • SJCGOP secretary/events chair Alexa Johnson distributed a text that said Schaetzle would be assigned as a greeter for the Lincoln Day Dinner. (see attached A and B)

   • Schaetzle was allowed to attend the Lincoln Day Dinner. (see attached C, D, E)

   • Schaetzle was permitted to advertise in the Lincoln Day Dinner program as the centerfold advertisement. (see attached F)

   • Schaetzle was permitted to attend monthly Republican meetings and events, including chairman’s breakfast (see attached G and H).

   • Schaetzle was invited to attend GOP parades (see attached I and J)

   • Schaetzle was featured in GOP Facebook posts (see attached K)

   • Jackie Horvath’s failure to uphold Party Rules by ignoring the direction of 2nd District Chair Courtney Papa who directed her not to permit Schaetzle to attend party meetings.

   • Chairwoman Horvath would not commit to keeping Schaetzle off the primary ballot as a Republican in 2026

Additionally – the following Violation of State Rules include:

   • Chairwoman Horvath violated Rule 3-3 (parts 2 and 3). Precinct chairs and vices do not meet primary rule and chair did not include signed authorization forms when adding new members to precinct list. Approximately 65 precinctmen and vices (out of roughly 300) are not qualified Republicans, and an additional six cannot be determined. Four were Democrats. That means almost one quarter of the precinct list members are unqualified or unverifiable list. Many are also not believed to be dues paying members of the SJCGOP or to be involved in regular party activities. • Jackie Horvath’s failure to notify many precinct committeemen that had been removed as required by PR-5. This list of removals included several elected officials, including state, county, and township. She demoted Rep. Tim Wesco from chair to vice chair and removed his relatives. She removed a GOP county councilman and his wife completely from the precinct list. She also demoted another councilwoman and her husband to vice chair. Additionally, she removed long time Republican women’s club members; elected town/township members; Tea Party members; and 2nd Amendment group members.

   • Chairwoman Horvath permitted a precinct committeeman who moved out of state to vote at reorganization; that precinctman remains on the precinct list, despite the fact that he lives in Michigan.

   • Chairwoman Horvath removed a vice chair (Chris Jones) chosen by an elected precinctman (Ashley Leader) to a new precinct, which included no notification to the precinctman.

   • Chairwoman Horvath removed approximately 17 precinct committeeman who are not in full alignment with her and left their precincts completely vacant.

   • Chairwoman Horvath permitted Dan Schaetzle, a Republican not in good standing, to vote in reorganization.

   • Chairwoman Horvath granted GOP Data Center access Schaetzle, despite the second district decision that he was not a Republican in good standing. State party had to intervene and block access.

Finally, Chairwoman Jackie Horvath has engaged in GROSS MISCONDUCT AFFECTING THE PARTY ORGANIZATION Rule 1-13(2), because her actions created and continue to create a poor reputation and perception of both the local and state GOP. These include all the points already listed above, as well as these additional reasons:

   • Permitted a known and prominent Democrat, Dan Caruso, a vocal public commenter at government meetings, to attend the July 2025 county party meeting. Also at the meeting included known “Republican” agitators, included in an effort to pad attendance numbers. (Kent Hizer and Ben Dallas, see attached L, M, N, O).

   • Almost exclusively uses middleman Sam Barke for the party’s election and consulting needs. She also co-owns a business with him. This creates a significant perception of impropriety impacting the entire local party organization. She spent $179,634.35 of party money with him in 2024. Apparent conflicts of interest exist because of the overlapping positions he holds, including at her personal company, Horvath Communications; as a consultant for the SJCGOP; as chief of staff for the SJCGOP; as a board of member of the Hoosier Conservative Voices PAC; and as a paid consultant for the Hoosier Conservative Voices PAC. He is also a precinct committeeman. Contracts require no bidding, nor approval from the executive board, and Barke’s invoices do not differentiate between his vendor costs and mark-ups.

Marvin “Joe” Layne Sharyl Dawes

Complainant Complainant

25638 State Road 4 & 1234 N Eddy Street; Apt. 208

North Liberty, Indiana 46554 South Bend, Indiana 46617

vs.

Jackie Horvath

Respondent

1202 Napoleon Street

South Bend, Indiana 46617

DECISION OF THE RULES COMMITTEE OF THE INDIANA REPUBLICAN STATE COMMITTEE

Pursuant to Rule 1-36(a) of the Rules of the Indiana Republican State Committee (“Rule(s)”), the Rules Committee (“Rules

Committee”) of the Indiana Republican State Committee (“State Committee”) convened on August 4, 2025, to consider

multiple complaints filed requesting the State Committee to remove the Respondent, Jackie Horvath, from her current

position as Chairwoman of the St. Joseph County Republican Party. The Complainants allege several acts of misconduct,

Rule violations, conflicts of interest, divisive actions a\ecting the party organization, and other malfeasance.

Before taking up the merits, the facts leading to these complaints must be addressed. Earlier this year, the 2nd

Congressional District O\icers (“District O\icers”) heard a complaint regarding St. Joseph County Councilman Mr. Dan

Schaetzle’s status within the party organization. The District O\icers heard evidence alleging Mr. Schaetzle publicly

encouraged voters to not vote for the Republican nominee running for probate court judge, Loris Zappia, and determined

Mr. Schaetzle violated Rule 1-25 and is not in good standing for a period of two (2) years, starting January 31, 2025. Mr.

Schaetzle subsequently appealed the decision to the State Committee and the District O\icer’s decision was upheld.

Publicly supporting any candidate other than a Republican nominee is a per se violation of Rule 1-25, which states, “The

term ‘Republican in Good-Standing’ shall be defined as a Republican who supports Republican nominees and who does

not actively or openly support another candidate against a Republican nominee.” Mr. Schaetzle violated Rule 1-25 and

forfeited his status in the party organization.

Complainants allege that the Respondent also violated Rule 1-25 by supporting Mr. Schaetzle after he was determined to

be not in good standing. The Rules Committee determined Rule 1-25 only applies to conduct occurring during a given

election cycle. That period begins during the candidate filing period and the date of the general election. The applicability

of Rule 1-25 to the allegations levied against the Respondent is not applicable. However, the Rules Committee determined

the conduct and behavior of the Respondent in allowing the continued support and participation within the St. Joseph

County Republican Party of Mr. Schaetzle as alarming and against the clear intent of previous rulings by the District

O\icers and State Committee.

Complainants allege, in their interpretation of Rule 1-311, that their complaint is valid in seeking the removal of the

Respondent as Chairwoman of the St. Joseph County Republican Party. Per Rule 1-31(3), any complaint may seek the

removal of any member or o\icer of any party committee. However, the Complainants allege that their complaint merits

removal for cause under Rule 1-13, which states“any willful violation of rules, resolutions, statutes pertaining to elections,

or gross misconduct a\ecting the party organization.” The Rules Committee determined the following:

Under Rules, the Respondent was not required to communicate the State Committee’s ruling of Mr.

Schaetzle’s appeal and subsequent status in the party organization to the county committee. Due to Mr.

Schaetzle having been duly found by the District O\icers to be in violation of Rule 1-25, Mr. Schaetzle’s

presence and promotion of his campaign at the St. Joseph County Lincoln Day Dinner should not have

1 Complainants cite Rule 1-30 in their initial complaint. This rule was recodified as Rule 1-31 by the State Committee on August 14, 2025.

been allowed. Due to Mr. Schaetzle having been duly found by the District O\icers to be in violation of

Rule 1-25, Mr. Schaetzle’s presence at monthly party meetings and gatherings should not have been

allowed nor the promotion of his campaign on the party’s social media accounts. Due to Mr. Schaetzle

having been duly found by the District O\icers to be in violation of Rule 1-25, Mr. Schaetzle should not be

allowed to run for any public o\ice as a Republican during the aforementioned period.

Complainants allege the Respondent violated Rule 3-3 with allegations of precinct and vice precinct

committeemen (“PCs & VPCs”) being purged and appointing individuals who do not meet eligibility

requirements. While appointed PCs and VPCs must be registered voters, county residents, and Qualified

Primary Republicans2

. Prior to August 14, 2025, certification of appointees who do not meet the 2-primary

voting record of a Qualified Primary Republican was not required. Appointed PCs and VPCs serve at the

county chair’s pleasure, and removal does not require notice. Although the county chair must update the

list for any changes, any complaint challenging an individual’s voting record or residency should have

been submitted to the District O\icers prior to the St. Joseph County GOP reorganization meeting. Mr.

Schaetzle was not explicitly removed by the District O\icers, making him eligible to participate at that

time. Mr. Schaetzle was subsequently removed as a precinct committeeman by the State Committee on

June 12, 2025. The Respondent did attempt to grant Mr. Schaetzle access to party tools and resources,

which was denied by the State Committee on June 12, 2025.

The question of who is permitted to attend party meetings, unless explicitly prohibited in writing by a

decision of the county, district, or the State Committee, is ultimately at the discretion of the county chair.

The county chair, as leader of the county party, has discretion on the administration and governance of

the county party. While the Respondent’s actions and style of governance may be divisive and create

frustration, such tactics do not violate Rules; although, these strategies may prove unwise over time.

While the State Committee takes the health of the county party seriously, we find these complaints frivolous. The

frustrations expressed in these complaints compels clarity on previous rulings regarding Mr. Schaetzle’s status within the

party. The Rules Committee will take the opportunity to clarify here. Mr. Schaetzle’s current status means that the

Respondent, in her capacity as the Chairwoman of the St. Joseph County Republican Party, shall not appoint him to any

party o\ice, shall not permit the attendance or presence of Mr. Schaetzle at any Republican Party events or functions,

shall not issue to Mr. Schaetzle access to any proprietary tools or resources of the party, and should not permit Mr.

Schaetzle to run for any public o\ice should Mr. Schaetzle attempt to do so during the aforementioned period. The Rules

Committee strongly encourages the Respondent to abide by the rulings of the District O\icers and State Committee.

The State Committee is highly reluctant to remove any duly elected o\icer of a county committee. Due to the number of

allegations against the Respondent, this decision shall serve as an o\icial reprimand against the Respondent. This

decision is final and not subject to appeal. However, due to the frivolity of these complaints, it is the hope and desire of

the State Committee that these issues not be revisited. If revisited, further action by the State Committee may be

warranted.

Sincerely,

Aaron Minnich

State Secretary

Indiana Republican State Committee

2 Rule 1-24 defines a Qualified Primary Republican as “a voter who cast a Republican Party ballot at the two (2) most

recent primary elections in Indiana in which the voter voted, and who is a Republican in Good-Standing.”